ML20101K270

Final Deficiency Rept DER 84-41 Re Adequacy of Cardinal Industrial Products Product Program for Supplier Qualification File.Item Not Reportable Per 10CFR50.55(e)

ML20101K270
Person / Time
Site:	Palo Verde
Issue date:	12/13/1984
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20101K274	List: ML20101K270 ML20101K297
References
ANPP-31474-TDS, DER-84-41, NUDOCS 8412310279
Download: ML20101K270 (12)

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Arizona Nuclear Power Project P.O. BOX 52034

• PHOENIX, ARIZONA 85072-2034 U

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!, q December 13, 1984 ANPP-31474-TDS/TRB h La s!~~

U. S. Nuclear Regulatory Commission Region V Creekside Oaks Office Park 1450 Maria Lane - Suite 210 Walnut Creek, CA 94596-5368 Attention: Mr. D.F. Kirsch, Acting Director Division of Resident Reactor Projects and Engineering Program

Subject:

Final Report - DER 84-41 A 50.55(e) Reportable Condition Relating to Adequacy of Cardinal Industrial Product Program For Supplier Qualification File: 84-019-026; D.4.33.2

Reference:

A) Telephone Conversation between P. Narbut and T. Bradish B) ANPP-ANPP-29809, dated June 22, 1984 (Interim Report)

C) ANPP-ANPP-30410, dated August 31, 1984 (Time Extension)

D) ANPP-30591, dated September 20, 1984 (Interim Report)

E) Telephone conversation between L. Miller and W.

E.

Ide on November 2, 1984 F) ANPP-31083, dated November 7,1984 (Time Extension)

G) ANPP-31190, dated November 20,1984 (Time Extension)

H) ANPP-31286, dated December 3,1984 (Time Extension)

Dear Sir:

Attached is our final written report of the deficiency referenced above, which has been determined to be Not Reportable under the requirements of 10CFR50.55(e).

Very truly you Cc_LL

/WLL E. E. Van Brunt, Jr.

APS Vice President Nuclear Production ANPP Project Director EEVB/TRB: dim Attachment cc:

See Page Two 8412310279 841213 W

I PDR ADOCK 05000528 Il:

S PDR

a Mr. T. W. Bishop

' DER 84-41 Page Two ec:

Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.

20555 T. G. Woods, Jr.

D. B. Karner W. E. Ide D. B. Fasnacht A. C. Rogers L. A. Souza D. E. Fowler-T. D. Shriver C. N. Russo B. S. Kaplan J. R. Bynum J. M. Allen D., Canady A. C. Gehr W. J. Stubblefield W. G. Bingham R. L. Patterson R. W. Welcher H. D. Foster D. R. Hawkinson R. P. Zimmerman M. L. Clyde M. Woods T. J. Bloom Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, GA 30339 D. N. Stover

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-FINAL'k5 PORT-DER.84-41

-DEFICIENCY EVALUATION 50.55(e) 1 ARIZONA PUBLIC SERVICE COMPANY (APS)-

PVNGS UNITS 1,'2, 3 I.

Description of Deficiency In October and - November of 1983, the NRC ' conducted ~ an~ l audit of Cardinal ' Industrial Products (CIP) and reported ~- the, following find-

.ings:

a.

The wrong size coupons had. been used to perform Charpy _ impact -

testing of ASME III, Class 1 bolts having diameters greater than-1.5 inches.

b.. The procedures used for.' impact testing were not consistent with' the code.

In' addition, the NRC' audit team expressed concern that CIP had noti a.

Adequately verified sub-supplier qualifications.

b.

Diligently followed ASME/ ASTM material upgrading procedures.

c.

Complied with ASTM and ASME material specifications in the heat treatment documentation for materials from sub-suppliers.

APS Audit of CIP On February 16, 1984, APS (acting on-information received from another utility) conducted an audit at CIP of their ASME. approved program and of APS direct procurements and found that CIP had:

a.'

Not performed required corrective action in a~ timely manner.

b.

Used an inspector who were not certified.

(Level I' inspector was used in acceptance evaluations).

c.

Lost or misplaced two audit reports for sub-suppliers.

The APS audit substantiated the NRC audit finding that CIP had been using the wrong size coupons to perform Charpy impact tests.

i NRC Audit of ANPP During April 1984, an NRC Region IV audit team conducted an.investi-gation at the jobsite.

During their exit interview, NRC questioned CIP's quality documentation for materials supplied to the PVNGS.

(At this time, the NRC inspector also explained the findings of their audit of CIP,.- although the final report was not then pub-lished).-

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Pinal Report DER 84-41~

-Page Two l

.Bechtel Invetigation of -CIP At the request.of APS, J Eechtel~ Procurement Supplier Quality /Techni-cal Services, Western Power Division, conducted a _ project investiga-

. tion at CIP on May. 14-16, 1984 Bechtel. discussed their concerns i

with CIP, and during this meeting - the 'NRC concerns.were confirmed.

.Then NCR PX-8529 was issued to document the questionable quality of.

gj' bolting materials supplied to the PVNGS = by CIP,' and APS removed CIP.

from their Approved Vendor _ Listing -(AVL)._

Subsequently, APS-requested both Bechtel_ and Combustion Engineering (C-E) to; delete CIP from their AVL for the PVNGS Project pending further investiga-s i

tion and validation of CIP practices.

1 Bechtel Audit of CIP At the request of Project, Bechtel conducted an NCA 3800 survey and -

an ANSI N45.2 audit on June 26-29, 1984 These 'Bechtel investiga-i tions/ audit resulted in the following concerns:

1.

No available English translation for some sub-suppliers' Certi-fled Material Test Reports (CMTRs);.

2.

Lack of documentation to verify adequate sub-supplier-approval 4

controls; i.e.,

surveys, audits, quality program manual reviews; i

1 3

Insufficient quality requirements imposed in procurement docu-

.ments to sub-suppliers; 4

Inadequate correlation between sub-suppliers' material testing 4

programs (chemical, mechanical, Charpy, IZOD) and - those. speci- -

fled in ASTM /SA mateial testing requirements; 5.

No documented evidence of qualification of trading companies with whom CIP does business:

l 6.

. Incorrect transcription of information f rom originating manu-1 facturer's material test reports to CMTRs;

. 7.

Failure to report impact data on CMTRs; 8.

No demonstrable direct control or supervision over sub-sup-plier's activities; 9.

Certification of wrong material grade on CMTRs;

10. CMIRs without cognizant organization's verification of compli-4 ance 'to NCA 3800 program.

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Inadequate ; impact.- testing related to (a) ' the use.of the ' IZOD impact -test method versus the ASME Charpy impact test method as

. an acceptable ASME/ ASTM test-and,(b) the -length. of the coupons used in relation to -material diameter as required, per. NX-2300 and ASTM A-370;.(No ASME III Class 1 material affected).

d:

Failure 'to conduct ' the NDE. examination for. ASME :III, Class,1, 12 material? greater than 1 inch in ' diameter : supplied under Bechtel-

' Field ' Purchase'.' Order

• NO.,10407-F-140441, dated December. 14,

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1981 (MT;or PT is required by NB' 2500)q;(Note - This material was previously scrapped due ' to lack of impact testing).

l-13.

Insufficient. heat -treatment documentation to verify the

< requirement of. correct stress relieving. temperature af ter cold drawing for AISI - 4140/SA 193B7 stud material.

...i' i

A11~ PVNGS purchase orders issued' to' CIP' were investigated. Approxi-mately 288 individual purchases addressing some 1234 separate line l

items.

It has been concluded that ; those items purchased from CIP during the time period December 1980 up to and including the present i

were. identical to the mateial types used during the overall con-struction activity.

This review process disclosed that some Field Material Requisitions (FMR's) did not contain enough information to properly identify the appropriate ASME code effective date. Alan, deficiencies were noted j

in (a). the QA review process of FMRs and (b) Receiving Inspection procedures for verifying compliance with ASME codes.

Evaluation Based on the NRC findings and subsequent Project investigations and audits, the PVNGS Project decided to implement a limited program to evaluate the adequacy of CIP material ~ supplied to Palo Verde.

The program consisted of' two parts:

(1) Review of documentation at CIP and (2) Materials testing. Subsequent to thses actions, CIP denied f

the Project access to their facility.

As a result of this, ' the q

l Project implemented a more comprehensive material testing program.-

The results are given below:

j A.-

Technical Evaluations 1.

Review of Data at CIP and Actions Taken L

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t' The investigation regarding the issue of impact testing with under-sized coupons was completed, and no ASME III l

Class 1 material at PVNGS has been found which would be I

affected. No further action is required at this time.--

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Final Report DER.84-41

't Page Four'

'The#ANPP h'as completed a review' of all.CIP purchase orders for ASME, Class 1 materit.ls. NDE or Charpy impact testing imposed as a requirement of the ASME Code,' Class.1, or imposed as a mandatory. requirement for certification to the applicable SA material specification was properly accomplished and no unacceptable material was found.

No further action is required at-this time.

The lecation of ASME Section III Class 1 materials for the NSSS was also determined.

Unit 1 has 12 bolts in t'.te High Pressure Caolor for the 1B Reactor Coolant Pump.'

These are 1 inch dia. 8 thd x 4-1/4" long bolts with nuts.

The bolt is SA-193 GR B7 and the nut SA-194 GR 7.

This material was identified as not - being affected by the impact testing issues.

A review of CIP documentation concerning the appropriate heat treatment of AISI-4140/SA 193B7 stud material showed that the bolts were furnished in the quenched and tempered' heat treat condition and the studs were furnished in the

quenched, tempered, and stress-relieved heat treat condition.

The studs were stress-relieved after the cold drawing operation as required by the material specification.

The effective ASME code for the PVNGS project is the 1974 Edition, Wint'er 1975 Addenda.

This code edition and addenda does not give a requirement for control of stress relief temperature.

For " cold drawing" of materials the only requirement is that the material shall be stress-relieved.

CIP is only required to provide documentation that the SA 193, B7 studs and bolts meet the requirements of Section II of the aforesaid ASME code.

No further action is required.

Also the following material deficiencies for ANPP were found:

Deficiency Discovered By Corrective Action a.

Sixteen 1-3/8" CIP

• NCR PA-8541 8 x 5-1/2" SA-564 Material returned TY 630 H1100 Hex Head to CIP Bolts. Lacked solution annealing heat treating b.

Twenty-Eight 1-1/2" CIP

• NCR NC-678 6 x 6-1/2" SA-326 Hex material scrapped Head Bolts-Class 1.

due to no impact r

i Lacked necessary testing magnetic particle examination and had loss of traceability

-c.

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Final Report DER ~84-41 Page Five i

Deficiency Discovered By Corrective ~ Action c.

Materials purchased on Project Review-

• Retested Field Order-Audit at CIP satisfactorily

1. 10407-F-140730.(150.

at CIP SA-193-B7 Studs 1-1/2" dia. x 8 x 6") Heat

1. 589B. Lacked impact test data d.- Heat #7536B Project

• Spec change-(1-1/4" x 8 x 6-1/2")

Review issued to SA-193-B7 Stud correct project material.

code effective Heat #8F784, A08320, date.

662540, 04059, 664524, Y0A3909, CY2647, CZ3929,

• ASME Section III B121270, 07930, 8F817, Class 2 Materials K8176, SA-194 do not require Material lacked evidence impact testing or Charpy impact testing 2.

Materials Testing Programs a.

Three material testing programs were performed during the project's evaluation of CIP.

A detailed descrip-tion of the different testing programs, the results of each program and the evaluation for each program has been provided in the attached presentation.

This presentation was presented to the NRC on November 13, 1984 and has subsequently been revised to include items discussed at that meeting.

b.

Test Summary / Technical Recommendation The extensive verification test programs described in l'

the Presentation confirmed that the material conformed i

to the applicable material specification and code requirements.

The noted variations to material specification l

requirements were minor and random and not indicative l

of any generic problem with the material furnished.

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. DER 84-41!

Page Six F

The mechanical. properties test resuts Lindicated good.

I ductility-even when yield ' and-ultimate tensile-

strengths were outside ~ thef range = specified.

The few I

deviations that occurred. are still well 'within design ;

safety factors.

i There was no indication that material was other than-2 what-it was. supposed. to be or' that. material manufacturing processes were not properly controlled.

The verification test results support the. conclusion

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that there is no materials quality _ problem with CIP l'

furnished materials.

Based upon the satisfactory results -of the above

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l extensive and thorough material verification program, ANPP is justified -in initiating action to disposition the delivered CIP material "use as is" and to ' allow use in construction of the existing warehouse material.

l' B.

,Programatic Evaluation o

i Due to the implication of this investigation, APS and Bechtel reviewed the total CIP procurement program for the PVNGS.- Upon conclusions of this in-depth : evaluation it was determined that the following weaknesses were apparent:

1 1.

NCA-3800 Surveys l

The PSQD NCA-3800 surveys were not definitive enough to 2

disclose the types of deficiencies found in CIP's quality-program.

Bechtel has enhanced the NCA-3800 survey check-lists to provide a more definite in-depth review.

This will assure the disclosure of those particular types of 2

quality documentation deficiencies found at CIP.

Bechtel j

is also in the process of evaluating the audit checklists l

format utilized for ANSI. N45.2 suppliers to preclude a l

recurrence of these types of deficiencies regarding the i

"Q" Class safety-related procurements.

I To provide additional assurances for other PVNGS fasteners t

suppliers, PSQD conducted an in-depth audit / survey of Texas Bolt and Loue Star Screw Companies.

This in-depth audit and survey showed-that the suppliers did not exper-i ience the material certification, documentation and test-

.ing problems experienced by CIP.

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Final Report DER 84-41:

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2.

Preparation'of-FMRs The preparation of Field Material Requisitions (FMR's)' by Engineering in some cases did. not contain the applicable code effective date.

The lack of. this information p re-cluded correct ordering of materials by Procurement.

Training sessions for responsible Field Engineering per-sonnel have been conducted, and Procedural Change Notice

1. 58 to. WPP/QCI 10. 0,'

was issued on October 29, 1984 requiring a mandatory entry for code effectivity date.

3.

QA Review of FMRs The systematic review of FMR's by Project Quality Assur-ance was not suf ficient to insure inclusion of proper code effective date on the FMRs.

i The QA checklist for review of FMRs reflected in l Project Quality Program Manual, Procedure 7.8, will be supp*.e-mented by desk instructions to provide specific guidelines relative to ASME Code requirements.

These supplemental.

Instructions will be implemented immediately.

4 Receiving Inspection 1

Project receiving procedures were not detailed enough' to identify those CIP materials lacking the required tests and examination certification.

Receiving Inspection Pro-cedures WPP/QCI 4.0 will be revised to require that CMTRs received for ASME III materials comply with the code date criteria for the Project.

C.

Conclusions The results of the above evaluation program support the con-clusion that the material received from CIP is satisfactory and is capable of performing its intended function.

There is no evidence that improper materials were used or that mateial manufacturing processen were not properly controlled.

Conse-quently - the project has taken the action to disposition NCR PX-8529 for the delivered CIP material "use as is" and to allow use of the existing materials ' for construction.

The defi-ciencies identified do not affect the safety of PVNGS.

The root cause;for the condition discussed in this DER is CIP's i

lack of control over their sub-suppliers and lack of attention

.to specific quality documentation requirements in ' acceptance /

issuance of material certifications.

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,-E Final Reporti s

DER'84-41D Page Eight s

a The audit ' checklists utilized by the Bechtel audit team (s) were s

not definitive enough to discern deficiencies relating.to CIP's 1.

control management. of foreign' sub-suppliers and foreign trading companies, as well as those. activities relating. to the' review e

of hardware documentation to detect. the lack of: impact -test results on CM1Rs, heat treat records, and NDE results.

A sub-issue of the DER is the Project's inattention -to detail when preparing and reviewing FMR's.

t 1

All that has been ' discussed above is summarized in the LPVNGS presentation to the. Mtc on this subject.. Revision 1 of that presentation, which is attached hereto, contains minor corree-tions to some of the data which was presented to the NRC.

II.

Analysis of Safety Implications j

Based on the above,. this condition is evaluated as not reportable -

under the requirements of 10CFR50.55(e) since no material has been found to be unfit for use.

This project. also has evaluated this t

condition as not reportable ucder 10CFR21.21(b)(3).

j III. Corrective Actions 4

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A.

Field Material Requisitions 1.

FMR procedures have been modified to require.the correct code effective date.

Procedural Change Notice #58 to WPP/QCI 10.0, was issued on October 29, 1984 requiring a J

mandatory entry for code effectivity date.

2.

The QA checklist for review of FMRs reflected in Project Quality Program Manual, Procedure 7.8, has been supple-mented by desk instructions to provide specific guidalines relative to ASME Code requirements and inclusion of all j

details as specified in WPP/QCI 10.0.

i' 3.

Additional training sessions for responsible Bechtel field engineers and QA personnel will be conducted, regarding i

FMR preparation.

These sessions are scheduled to be com-pleted by January 5, 1985.

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~ DER 84-41 Page Nine B.

' Vendor Qualifications During project audits and. surveys of PVNGS.-suppliers,; more, emphasis will ~be placed on hardware produced and, related quality documentation.

1.

Bechtel revised their audit checklists to provide a more definitive review..

(a)

The-NCA-3800 survey checklist was. enhanced to uncover.the particular -types of documentation deficiencies found at CIP..

(b)

Bechtel has evaluated the audit and survey checklist.

format of the ANSI N45.2 suppliers to preclude. a recurrence of these types of deficiencies regarding ~

the "Q"

Class safety-related. procurements..

The checklist has been revised..

2.

Bechtel is including appropriate technical personnel on all NCA 3800 surveys.

3.

Bechtel is conducting training sessions ' concerning utili-zation of the new checklists.

This is scheduled to be complete by January 2, 1985.

4.

Bechtel is including I&E information notice 84-52 with all audit packages as a guide. -

C.

R_eceiving Inspection i

1.

Receiving Inspection Procedure WPP/QCI 4'. 0 has been revised to require that CNIRs received for ASME III mat-erials comply with the code effective date criteria for the Project.

I 2.

QC inspectors will receive additional training in the use of the ' applicable code and standards.

This training is scheduled to be complete by January 5, 1985.

3.

User's test will be instituted for bulk bolting materials deliverd to the jobsite.

These tests will be primarily hardness with mechanical and chemical tests as required.

This Test Program is scheduled to be implemented 'by December 31, 1984.

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Final Report DER 84-41 Page Ten '

4.

A sample of fasteners CMTR's received from other Suppliers will be reviewed and evaluated for - code compliance by December 31, 1984.

D.

Overall An integrated audit of procurement, receiving. inspection and material control (warehousing) will be performed.

This audit is scheduled for completion by December 21, 1984.

IV.

References 1.

CE Letter V-CE-30294 May 24, 1984.

2.

AISC Manual for Steel Construction.

3.

High Strength Bolting - Bethlehem Steel Issue #5 December 1977.

V.

Attachment - PVNGS Presentation to the NRC on Cardinal Industrial Fastener Materials November 13, 1984 35 Pages.

Rev. 1 November 16, 1984, Rev. 2 December 12, 1984.

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